EAR “Escape Room” Encryption, De Minimis, and Foreign Direct Products

Posted on December 13, 2019 · Posted in


EAR Seminar
Wednesday, January 22, 2020
1:00 — 4:00 p.m.

Professional Association of Exporters and Importers


EAR “Escape Room” Encryption, De Minimis, and Foreign Direct Products

The US encryption export controls have many exemptions that allow products to “escape,” fully or partially, from control under Category 5, Part 2. Some are broad, some are narrow, and many can be self-certified, without having to file an encryption classification request. Sometimes, companies impose higher levels of export controls on products using encryption, because they are not confident about using these exemptions.

This session will focus on interpreting and applying the exemptions to various types of products, exploring how the key exemptions work.  The session will cover:

  • Definition of “cryptography” for non-cryptographers
  • Understanding the relationship between the former “ancillary” and “Note 4” concepts and revised ECCN 5A002.a.1 “primary function” concepts
  • Scope of specific exclusions
  • EAR jurisdiction over foreign-made items that incorporate US-origin encryption
  • Published items / open-source encryption / open-source derived products
  • De minimis eligibility for encryption items
  • 5A992/5D992 Mass Market eligibility
  • De Minimis Rules
  • Foreign Direct Product Rules

Date:  Wednesday, January 22, 2020

Time: 1:00 — 4:00 p.m. PST

NVIDIA Corporation
2788 San Tomas Expressway
Santa Clara, CA 95051

Registration: $50 for P.A.E.I. members/$75 for non-members

**Not a member? Consider becoming a PAEI member today!
**The cost of an individual membership gives you the benefit of attending this seminar at the member rate!  And you’ll be able to enjoy more benefits during your membership term.  Talk about a deal!**

  • Individual Membership only: $50
  • Corporate Membership only: $150

For registration questions, please contact Marit Fox at PAEIAdmin@paei.org.


2788 San Tomas Expressway, Santa Clara, California, 95051, United States

  • EAR Seminar
    January 22, 2020
    1:00 pm - 4:00 pm
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